ML20054L806

Emergency Planning Contentions

ML20054L806
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/01/1982
From:	Shapiro R Cammer & Shapiro, NORTH SHORE COMMITTEE AGAINST NUCLEAR & THERMAL POLLU
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20054L804	List: ML20054L803 ML20054L806
References
ISSUANCES-OL, NUDOCS 8207080496
Download: ML20054L806 (6)

Text

r

,?

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

.LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 0.L.

) (Emergency Planning (Shoreham Nuclear Power ) Proceedings)

Station, Unit 1) )

)

)

EMERGENCY PLANNING CONTENTIONS (NSC, j oined by SOC. SC will participate as an interested County pursuant to 10 CFR 52.715)

PRELIMINARY The contentions which follow are the distillation of many hours the Staff and ofconferencecallsamongcounselfortheinteryenors, LILCO to comply with the Board's April 20, 1982, Order t,o file consolidated contentions and to attempt to resolve differences with LILCO and the Staff.

N,SC submitted a draft of its contentions to the other parties on June 16, 1982. SOC and Suffolk County submitted their contentions on that and the following day. A lengthy conference call ensued on June 21, 1982, among counsel for the inter'venors, the Staff and LILCO to attempt to resolve issues arising from the separate submissions and to file a consolidated pleading, as directed by the Board.

Counsel for the Staff, LILCO and Suffo'lk County conferred in Washington, D.C. on June 30, 1982. Counsel for NSC was unable to 8207000496 820701 PDR ADOCK 050003gg t G

." attend due to prior professional commitments. However, during a conference call that afternoon, counsel for LILCO alleged that NSC contentions were in a form which did not permit ready identification of the particulars of its contentions and were argumentative.

Rather than spend the time of the Board and of the parties in .a proceeding to determine the merits or lack thereof of LILCO's objections to the draft contentions and to meet the Board's filing schedule, NSC's counsel undertook to revise it's draft, without sacrificing substance, to meet his understanding of LILCO's objections and to serve the revised contentions on couns'el for LILCO, the Staff

.and the other intervenors no later than Friday, July 2,1982. The result of this commitment follows.

n Time and co~straints (and the intervening holiday weekend),

will apparently not permit the filing in the form of consolidated contentions by July 6,1982, the date established by the Board.

However, we believe that there is neither duplication, overlap, nor redundancy between NSC's contentions and SOC's contentions and SC's contentions, and thus the spirit and purpose underlying the Board's order for a consolidated filing has been met.

FAILURE OF SHOREHAM/LILCO'S EMERGENCY PLANS TO COMPLY WITH NRC/ FEMA REGULATIONS NSC 1(EP):

Notification- procedures established by LILCO to communicate with State and local response organ-izations do net meet the requirements of 10 CFR l

50. 47 (b) ,1,, (2), (3), (4), (5), and (6); 10 CFR Part 50, appendix E.II.C, G, H and IV.E.9.

Bases:

(1) Both the dedicated and commercial telephone lines and the lou-powered UHF radio station upon which Shoreham's notification /

4 .

communications network rely are inadequate.

(2) Given the significant probability that the telephone system will break down, suffer a p2mr overload or be sabotaged by

hostile forces, and the absence of a backup power source, there is l a strong likelihood of inadequate and untimely notification to State and local response organizations.

(3) LILCo's plan does not take into account the history of power outages in Long Island which have rendered telephone systems inoperable for extensive periods of time.

(4) The placement of telephone lines overhead exposes the telephone communications system to sabotage and extreme weather conditions.

(5) The breakdown of the telephone system in the event of an emergency shutdown at the plant or an overall system overload would prevent LILCO from assigning and specifying primary responsibilities for emergency response between the applicant and State and local .

~

response organizations. .

~ ~

(6) Measures to communicate with key pla e personnel who may not be in the plant or at home when an emergency occurs have not been adequately addressed.

(7) Insufficient personnel are connected to the " hotline" to satsify the requirements of the regulations.

(8) LILCO's plan does not address the stress and strain to which the personnel assigned to response and notification may be subjected when confronted with a previous'af unexperienced radiological emergency.

(9) LILCO has assigned too few Emergency Operations Facility personnel to transmit the key information to offsite emergency support and response organizations from an onsite location.

f (10) The communication / notification system is inadequate to arrange for, request, and effectively use assistance resources.

(11) The communication / notification system does not assure State and local response organizations that LILCO will be able to provide them with the information which they require to determine minimum initial offsite response measures.

(12) The Electrical Emergency Restoration Procedure does not meet the criteria for an adequate backup power source.

(13) The plan presents insufficient data about the coverage and load capacities of the low-powered UHF base radio station to assess its capabilities if a breakdown in the primary telephone systems should occur.

NSC 2(EP): Communications between LILCO and St. ate and local response organizations do not meet the federal standards in 10 CFR 50.47 (b) (1), (3), (5), (6),

(7) and (8); 10 CFR Part 50, Appendix E.II.G and Appendix E.IV.D.1, D.3, amd Appendix E.IV.E.9. -

Bases:  :

The interaction between the notification contentions, (NSC 1 (EP)), and this contention is~ obvious. The following particularizations of this contention are added and do not overlap contention NSC 1(EP).

'(1) Communications with the outside governmental agencies ,

the Media and the public are inadequately staffed, briefed and technically equipped to ensure a coordinated dissemination of vital information to these offsite sources of support and response implement-ation.

(2) The plan presents insufficient data to determine if the

, i.

,' two-way UHF radio between the control room of the plant and the ENS will not malfunction, suffer an overload or interference.

(3) The plan presents insufficient data to determine if LILCO's "uninterruptible power source" to back up their party line system (Rev. B, Shoreham Annex, 55. 7.7) , is both adequate -

and capable of being implemented.

(4) Assignment of the Health Physics Engineer to sole responsibility for ensuring the availability of the communication equipment during emergency conditions is both impruden't and unrealistic.

(5) The plan gives an inordinate amount of responsibility

'to the Emergency Director, but has not included the Emergency Director's private home in the network of those accessible to the Private Automatic Exchange.

-(6) The plan does not consider that the Emergency Director may not be able to perform the non-delegable tasks assigned to him/her.

(7) The plan gives inadequate consideration to the possibility that the Emergency Director or the Response Manager may make commu-nication decisions or allocate the limited communications resources in a manner in conflict with the county or State's decisions in these areas.

NSC 3(EP): Arrangements for assistance resources needed onsite, particularly medical and emepgency transportation assistance, do not meet 10 CiR 50.47 (b) (3), (5),

(6), (8), (10), (11) and (12), as mandated by the NRC.

Bases:

(1) There is no assurance that medical personnel will be notified, or if notified, will be available, in sufficient time to

r

,' provide medical assistance.

(2) The plan does not assure adequate transportation and medical assistance to transport contaminated and/or injured persons from an irradiated area for medical treatment.

(3) There is no contingency plan to deal with unpreparedness, overcrowding, refusal to contaminate other patients and workers by the emergency facilities.

(4) LILCO's plans do not adequately correlate medical assist-ance with the different types of emergency classifications.

(5) The plan does not provide reasonably specific indicia of the contents of the applicant's messages to the emergency assistance workers and agencies in their relationship to the differ-ent classifications of an emergency.

(6) The provisions for backup medical assistance with the requisite training, facilities and preparation to respond to an emergency are inadequate.

(7) The letters of agreement with the medical and other facilities are not current and, additionally, d-o not specify the functions each will perform.

July 1, 1982 Respectfully submitted, Cammer & Shapiro, P C.

By: 1 falpli Shapi/o, Esql 9 East 40th Street New York, N.Y. 10016 (212) 683-6790 Attorney for North Shore Committee Against Nuclear and Thermal Pollution.

i

_c.

i

[